PIERRE, S.D. (KELO) — The South Dakota Supreme Court has made an important decision regarding division of marital property in a divorce.
The justices unanimously ruled Thursday that a substantial amount of the value of a Kingsbury County farm owned by a previously married couple from rural Lake Preston shouldn’t automatically be the property of solely one spouse.
The state’s high court found that Circuit Judge Gregory Stoltenburg erred and ordered that he look again at the matter.
The case involved a crop farm east of Lake Preston that Dennis Ryland sold for $300,000 to Matthew and Aren Field through a 2006 option. Ryland was a relative of Matt Field and wanted to keep the property in the family, because Ryland’s great-grandfather had homesteaded the land in 1878.
Justice Mark Salter in his written decision determined that Ryland sold the property to the Fields for a price that was “significantly below its market value.”
In 2010, the Fields exercised their option. Both Matt and Aren signed the contract for deed. It described them as joint tenants with rights of survivorship, the Supreme Court’s decision said.
In 2016, Aren filed for divorce. She and the couple’s children moved away. Aren and Matt stipulated to a divorce on the grounds of irreconcilable differences, but they weren’t able to reach agreement on the division of marital property and child custody.
At the subsequent trial on the unresolved issues, Matt introduced evidence that the Ryland property was worth $1,826,000 in 2010 when he and Aren bought it and was worth $2,200,000 at trial.
Matt’s lawyers, Todd Wilkinson and Gary Schumacher, wanted only the discounted $300,000 purchase price and the appreciated value of $374,000 included in the marital estate. They argued the $1,526,000 should be excluded because it represented the value of Ryland’s gift to Matt.
Judge Stoltenburg agreed with Matt Field’s position and excluded the $1,526,000. Aren Field’s lawyer, Jennifer Goldammer, then appealed to the Supreme Court. Justice Salter decided that the gift argument explained the reason for why Ryland sold the property for $300,000 but didn’t address to whom Ryland sold it.
The justice determined Aren shouldn’t have been excluded from the $1,526,000 value.
“The couple made annual payments during the marriage with marital funds to which Aren contributed her earnings. Although the circuit court was free to consider Dennis’ donative intent, it cannot be used to revise the historical facts associated with Dennis’ gift which, the undisputed evidence establishes, included Aren,” Salter wrote.
Salter based that part of his decision on the court’s ruling in a 2005 case, Godfrey v. Godfrey. Salter further said the Field case would have been returned to circuit court regardless because Aren Field had contributed financially to the annual payments and had a need for support after the divorce.
Wrote Salter, “We have consistently held that spouses can provide valuable contributions to the acquisition and maintenance of inherited or gifted property by acting as homemakers or working separately to assist the other spouse in maintaining inherited or gifted property.” He referred to a 2015 decision in the Anderson case and a 2018 decision in Ahrendt v. Chamberlain.
“Here,” wrote Salter, “there is evidence that Aren acted as the principal homemaker
and caretaker for the children. She also worked outside of the home and
contributed to the family’s income. Her earnings were deposited into a joint account
that was used to make payments on the Ryland Farm. There is also evidence that
Aren assisted directly with the couple’s overall farming operation by, among other
things, bottle-feeding lambs, delivering grain, driving truck during harvesting, and
preparing and delivering meals to Matt and Dennis in the field.”
Salter said Judge Stoltenburg didn’t consider whether Aren Field’s “seemingly beneficial contributions” should have been part of the circuit court decision.
“The circuit court abused its discretion in excluding the value of Dennis’ partial gift from the marital estate because the entire value of the Ryland Farm should be subject to equitable division,” Salter concluded.
Read the full Field v. Field decision below.